Groups
Controlled foreign companies update: Treasury invites comments by 10 February
HM Treasury has published an update and more draft legislation dealing with reform of the controlled foreign companies (CFC) rules.…3 Feb 2012
India’s top judges uphold ‘genuine strategic tax planning’
The decision of India’s Supreme Court in favour of Vodafone on 20 January is a ‘landmark decision’ for the foreign…31 Jan 2012
2011 review: in-house teams
Paul Morton reviews the top five tax developments in 2011 affecting in-house teams.15 Dec 2011
The decision of the ECJ in National Grid Indus: is the UK migration charge contrary to EU law?
On 29 November 2011, the Court of the European Union (ECJ) published its decision in the National Grid Indus case…8 Dec 2011
Eurodad steps up campaign for country-by-country reporting
Multinational ‘tax dodges’ are estimated to account for over half of all illicit capital flight from developing countries, the European…29 Nov 2011
Back to basics: Permanent establishments
Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.18 Nov 2011
Roundtable discussion: tax competitiveness and CFC reform
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.11 Nov 2011
Ask an expert: International transfer of property
Robert Langston answers a reader's question on the international transfer of property.11 Nov 2011
CFC ConDoc: observations on the HMRC analysis of EU law
CFC reform is one part of the grand bargain with UK plc over the taxation of foreign profits, and from…27 Oct 2011
Updates to HMRC's International Manual
Sarah Norton summarises the changes regarding real-time working of transfer pricing issues and Advanced Pricing Agreements, cost contribution agreements and share options27 Oct 2011
M&S: cross-border group relief
The Court of Appeal has handed down the latest judgment in the M&S group relief case. Alison Last assesses the impact of the decision.20 Oct 2011
Tax and the City: October 2011 update
Helen Lethaby reviews the latest developments, including anti-avoidance concerning manufactured overseas dividends.20 Oct 2011
Comment